TRAIL RIDGE INVESTMENT ADVISORS, LLC

ITEM 1 Form ADV Part 2A Firm Brochure October 9, 2025 This Brochure provides information about the qualifications and business practices of Trail Ridge Investment Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at (970) 305-5150, or via email at Jeff.Kadavy@TrailRidgeWM.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Trail Ridge Investment Advisors, LLC is a registered investment advisory firm. Registration of an investment advisory firm does not imply a particular level of skill or training. Additional information about Trail Ridge Investment Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Trail Ridge Investment Advisors, LLC IARD # 284741 A Subsidiary of Trail Ridge Wealth Management, Inc. 2020 Caribou Drive, Suite 102 Fort Collins, CO 80525 (970) 305-5150 Jeff.Kadavy@TrailRidgeWM.com www.TrailRidgeWM.com  ITEM 2 Material Changes Since its last amendment was filed on May 3, 2025, we have disclosed information regarding: • The new Trailhead Financial Advisory Service™ (Trailhead), which represents the consolida- tion and replacement of the former ongoing financial advice subscription and Trailhead In- vestment Management Service™; • Fees charged for Trailhead; • Model allocations for Trailhead; • The elimination of the separate Form ADV Part 2A for the Trailhead Investment Management Service™; and • The introduction of a minimum fee for hourly financial planning engagements. In the future, this section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last filing of this Brochure. This section will also identify the date of our last annual Brochure update. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year end, which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure can be requested at any time, without charge, by contacting us at (970) 305-5150, and is available on our website at https://www.trailridgewm.com/regulatory-filings. 2 Trail Ridge Investment Advisors, LLC  ITEM 3 Table of Contents ITEM 1 Cover Page 1 ITEM 2 Material Changes 2 Table of Contents ITEM 3 3 Advisory Business ITEM 4 4 Fees and Compensation ITEM 5 6 Performance-Based Fees and Side-By-Side Management ITEM 6 8 Types of Clients ITEM 7 9 ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss 9 ITEM 9 Disciplinary Information 13 ITEM 10 Other Financial Activities and Affiliations 14 ITEM 11 Code of Ethics, Participation in Client Transactions, and Personal Trading 14 ITEM 12 Brokerage Practices 15 ITEM 13 Review of Accounts 18 ITEM 14 Client Referrals and Other Compensation 18 ITEM 15 Custody 18 Investment Discretion ITEM 16 19 ITEM 17 Voting Client Securities 19 ITEM 18 Financial Information 19 Trail Ridge Investment Advisors, LLC 3  ITEM 4 Advisory Business FIRM INFORMATION Trail Ridge Investment Advisors, LLC (TRIA, we, us, or our), a limited liability company, became a registered investment advisory firm in 2016. PRINCIPAL OWNERS TRIA is owned and controlled by Trail Ridge Wealth Management, Inc. David Chadwick Jones, Jef- frey B. Kadavy, Mark K. Kerwood, Peter B. Loritz, and Jacqueline C. Zipser own and control Trail Ridge Wealth Management, Inc. Jeffrey B. Kadavy services as the Chief Compliance Officer of TRIA. INVESTMENT ADVISORY SERVICES Portfolio Management TRIA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. TRIA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Determine investment strategy • Tailor a personal investment policy • Asset allocation • Asset selection • Assessment of risk tolerance • Regular portfolio monitoring TRIA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. TRIA will require discretionary authority from portfolio management clients in order to select securities and execute transactions without permission from the client prior to each transac- tion. However, TRIA may present private investment opportunities to clients who are self-described accredited investors. In such cases, clients will determine whether to invest, how much to invest and from which account(s) they will invest. TRIA seeks to make investment decisions in accordance with the fiduciary duties owed to its accounts and without consideration of TRIA’s economic, investment, or other financial interests. To meet its fiduciary obligations, TRIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TRIA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is TRIA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (IPOs) and other investment opportunities that might have a limited supply among its clients on a fair and equi- table basis over time. TRIA will manage the investments in client accounts within the asset class ranges provided for the investment objective selected in each client’s Investment Policy Statement (the ranges). However, due to fluctuations or volatility in the capital markets, investment performance, maturities of securities, and/or other reasons, the investments in the accounts may move out of alignment with one or more of the ranges. At its discretion, TRIA will rebalance client accounts to conform to the ranges. Factors 4 Trail Ridge Investment Advisors, LLC  influencing the timing of such rebalancing include (i) the degree to which the accounts are out of alignment with one or more of the ranges; (ii) whether purchases or sales of securities are needed; (iii) whether any short-term trading fees would be assessed; (iv) TRIA’s assessment of the markets and economy at the time; (v) if one or more of the Account(s) are taxable, (I) the extent to which capital gains would need to be realized in such Account(s), and (II) the amount of time remaining in the tax year; and (vi) any other factors TRIA may deem appropriate. Financial Planning We provide two financial planning services that are designed to help you understand your overall fi- nancial situation and help you set financial objectives. We help you review your financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objec- tives. We provide our financial planning services on either an hourly basis or through our Trailhead Financial Advisory Service™ (see below). Generally, financial planning provided on an hourly basis will include preparing a comprehensive written financial plan. Trailhead Financial Advisory Service™ Trailhead Financial Advisory Service™ (Trailhead) is an ongoing financial advice subscription service. Financial advice offered through Trailhead may not necessarily include preparation of a comprehensive written financial plan; it includes “on-call advice,” where an advisor answers your financial questions as they arise on an ongoing basis. If desired, Trailhead includes an index fund-based portfolio manage- ment offering intended to help professionals who are early in their careers begin to invest for the future. SERVICES LIMITED TO SPECIFIC TYPES OF INVESTMENTS TRIA generally limits its investment advice to mutual funds, fixed income securities, exchange-traded REITs, insurance products, including annuities, equities, ETFs (including ETFs in the digital assets, commodities, and precious metal sectors), treasury inflation protected/inflation-linked bonds, and non-U.S. securities. TRIA will provide investment advice regarding exchange-traded REITs and an- nuities; it may invest in exchange-traded REITs for client portfolios but will not invest in annuities. Other securities may also be used to help diversify a portfolio when applicable. TRIA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements, as well as a plan that will be executed by TRIA on behalf of the client. TRIA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs, which restrictions will be documented in the Investment Policy Statement. However, if the restrictions pre- vent TRIA from properly servicing the client account, or if the restrictions would require TRIA to deviate from its standard suite of services, TRIA reserves the right to end the relationship. WRAP FEE PROGRAMS TRIA does not participate in or offer wrap fee programs. ASSETS UNDER MANAGEMENT As of December 31, 2024, TRIA managed $288,981,525 on a discretionary basis and $5,301,060 on a non-discretionary basis. Trail Ridge Investment Advisors, LLC 5  ITEM 5 Fees and Compensation PORTFOLIO MANAGEMENT FEES TRIA is compensated for portfolio management services by a negotiable fee based on total assets under management. Fees and billing will be pre-determined in writing in an Investment Advisory Agreement executed by the client and TRIA. TRIA has different fee schedules for its different discretionary management approaches: with options, without options, and for trusts (excluding life insurance trusts), of which TRIA’s affiliate, Trail Ridge Trust Company, LLC, is a trustee. Discretionary Portfolio Management with Options Total Assets Under Management Annual Fee $1 - $1,000,000 1.10% $1,000,001 - $3,000,000 0.95% $3,000,001 - $5,000,000 0.70% $5,000,001 - $10,000,000 0.55% $10,000,001 + 0.45% * Minimum annual fee of $5,000 and minimum equity portfolio of $700,000. Discretionary Portfolio Management without Options Total Assets Under Management Annual Fee $1 - $1,000,000 1.00% $1,000,001 - $3,000,000 0.80% $3,000,001 - $5,000,000 0.60% $5,000,001 - $10,000,000 0.50% $10,000,001 + 0.40% * Minimum annual fee of $2,000 and minimum account size of $200,000. Discretionary Portfolio Management for Trusts of which Trail Ridge Trust Company, LLC is a Trustee Annual Fee Total Assets Under Management $1 - $1,000,000 0.80% $1,000,001 - $3,000,000 0.70% $3,000,001 - $5,000,000 0.45% $5,000,001 - $10,000,000 0.30% $10,000,001 + 0.20% 6 Trail Ridge Investment Advisors, LLC  Total Assets Under Management Discretionary Portfolio Management for Trailhead Financial Advisory Service™ Annual Fee Up to $120,000 Included Over $120,000 1.00% * Minimum account size of $5,000. For additional information, see the Trailhead Financial Advisory Service™ information in the Financial Planning Fees section below. All fee and account minimums described above may be waived at TRIA’s discretion. In its discretion, TRIA may combine the balances of related accounts for fee calculation purposes. In such cases, one minimum annual fee will be charged across the group of related accounts. Fees are paid either monthly or quarterly in arrears. TRIA uses the average daily balance of the client’s accounts for the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Asset-based portfolio management fees are either withdrawn directly from the client's accounts or invoiced and billed directly to the client; clients may select the method in which they are billed. With respect to managed accounts held with a custodian with which TRIA does not have a custodial arrangement (typcally defined contribution plan participant accounts), fees are withdrawn directly from the client’s taxable account(s) as directed by the client. If the client does not have a taxable account, fees will be invoiced and billed directly to the client. For fees deducted directly from client accounts, in states that require it, TRIA will: (A) Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. (B) Utilize a custodian that sends at least monthly statements reflecting all additions and deduc- tions, including the amount of advisory fees. (C) Send the qualified custodian written notice of the amount of the fee to be deducted and send the client a written invoice upon or prior to fee deduction itemizing the fee, including the formula used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. For contracts terminated mid-billing period, clients will be responsible for paying the prorated advisory fee (earned but unpaid), using the average daily balance of the client’s accounts for the billing period through the date of termination. These fees are generally negotiable, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of TRIA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days written notice. Trail Ridge Investment Advisors, LLC 7  FINANCIAL PLANNING FEES Hourly Fees The hourly rate for financial planning services is $250, with a minimum fee of $1,000 per engagement. Trailhead Financial Advisory Service™ TRIA charges a recurring annual base fee of $1,200 ($100 per month). The base fee includes up to six (6) hours per year of financial advice time, whether meeting time or analytical/preparation time; addi- tional time will be charged at $250 per hour. The fee is due and payable monthly or quarterly in advance (unless the fee will be debited from an account managed by TRIA, in which case it will be paid in arrears), as provided in the Financial Planning & Advice Agreement. Trailhead engagements are for a minimum of one year, but may be renewed in writing by the client and TRIA for successive one-year terms. If a Trailhead client desires for TRIA to provide discretionary portfolio management services, the Trail- head base fee includes management of accounts up to $120,000 in market value; amounts above $120,000 will be charged the Discretionary Portfolio Management for Trailhead Financial Advisory Ser- vice™ fee described in the Portfolio Management Fees section above. Other Fee Information Hourly fees and Trailhead fees may be paid by check, electronic funds transfer, credit card, debit card, or debit from an account managed by TRIA, and may be discounted or waived at TRIA’s discretion. Fees for hourly financial planning services are charged in arrears upon completion of the engagement; if a Financial Planning & Advice Agreement is terminated before completion, you must pay the earned but unpaid fee, based upon the hourly rate and the number of hours worked or the minimum fee, whichever is greater. Clients may terminate the Financial Planning & Advice Agreement without pen- alty for a full refund of TRIA’s fees within five business days after signing it. Thereafter, clients may terminate the Financial Planning & Advice Agreement upon written notice; any paid but unearned fees will be refunded on a pro-rated basis. OTHER EXPENSES AND FEES The fees discussed above include payment solely for the investment advisory services provided by TRIA and are separate to certain fees or charges that are imposed by third parties in connection with invest- ments made on your behalf for your account. Third-party fees may include markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees. ADDITIONAL COMPENSATION Neither TRIA nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds ITEM 6 Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees, which are fees based on a share of capital gains on or capital appreciation of your assets. 8 Trail Ridge Investment Advisors, LLC  ITEM 7 Types of Clients We provide our investment advisory services to: • Individuals • Charitable Organizations • Trusts • High Net Worth Individuals • Insurance Companies • Retirement Plans Please refer to Item 5 for information regarding account minimums. ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss METHODS OF ANALYSIS We use various methods of analysis and investment strategies, including the following: Fundamental Analysis – We evaluate economic and financial factors to determine if a security may be underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to determine its intrinsic value by examining related financial, economic, and other qualitative and quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the security's value, from macroeconomic factors (like the overall economy and industry conditions) to individually specific factors (like the financial situation and management of companies). The overall objective of performing fundamental analysis is to determine a value that an investor can use to determine what sort of position to take with that security. This method of security analysis is contrary to technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Modern Portfolio Theory - Modern portfolio theory (MPT) is a risk-averse theory that involves the construction of portfolios to maximize and optimize expected return based on a given level of market risk, emphasizing that risk is an inherent part of higher reward. According to the theory, it’s possible to construct an efficient frontier of optimal portfolios offering the maximum possible expected return for a given level of risk. INVESTMENT STRATEGIES When formulating investment advice or managing client assets, we will use the following investment strategies. There are inherent risks associated with each of these strategies. Long-Term Strategy – A long-term strategy may not take advantage of short-term gains or may expe- rience more volatility over the life of the portfolio. Options Transactions – This strategy includes the risk that an option may expire out of the money, resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Trail Ridge Investment Advisors, LLC 9  Model Allocations – Each investment objective contains ranges for different asset classes. Portfolio rebalancing will be conducted periodically. These model allocations do not apply to Trailhead. Current Income. This objective seeks to provide a stable stream of current income, with a modest opportunity for capital appreciation to mitigate inflation. Pursuit of these objectives can result in a moderate level of principal volatility. The core of the strategy is investment in fixed-income securities, which provides portfolio stability and generates income, but a meaningful portion of the strategy may be allocated to equities. Fixed income investments consist primarily of bonds with intermediate ma- turities. Equities consist primarily of dividend-yielding stocks. Asset class ranges: Fixed Income: 50% - 80% Money Market: 0% - 10% Equities: 10% - 40% Other*: 0% - 20% Income with Growth. This objective seeks to provide current income and the opportunity for capital appreciation. Pursuit of these objectives entails a moderate level of principal volatility. The core of the strategy is investment in fixed-income securities, which provides portfolio stability and generates in- come, coupled with a substantial equity allocation. Fixed income investments consist primarily of bonds with intermediate maturities. Equities consist primarily of dividend-yielding stocks. Asset class ranges: Fixed Income: 40% - 70% Money Market: 0% - 10% Equities: 20% - 50% Other*: 0% - 20% Balanced. This objective seeks to provide long-term capital appreciation and some income generation. Pursuit of these objectives entails a somewhat higher level of principal volatility. The core of the strategy is a blended mix of fixed-income and equity securities. Given the dual objectives, holdings in equities and fixed income may be roughly equal. Asset class ranges: 25% - 55% Fixed Income: Money Market: 0% - 10% Equities: 35% - 65% Other*: 0% - 20% Moderate Growth. This objective seeks to provide both long-term capital appreciation and modest income generation. Pursuit of these objectives entails a higher level of principal volatility. The core of the strategy is investment in equities. There is also a meaningful allocation to fixed-income securities, which generates a modest level of income and can mitigate volatility. Fixed-income investments em- phasize total return. Asset class ranges: Fixed Income: 10% - 40% Money Market: 0% - 10% Equities: 50% - 80% Other*: 0% - 20% Growth. This objective seeks to provide long-term capital appreciation. Current income is not a con- sideration. Pursuit of this objective entails a high level of principal volatility. The core of the strategy is investment in equities, with a goal of achieving returns commensurate with the equity markets. Any fixed-income investments emphasize total return. Asset class ranges: 0% - 20% Fixed Income: Money Market: 0% - 10% Equities: 70% - 100% Other*: 0% - 20% * Other includes investments that have characteristics of both fixed income and equity, or which in TRIA’s judgment are not clearly classified as either. Examples may include preferred stock, real estate, commodi- ties, hedge funds, liquid alternative investments (e.g., long-short, merger arbitrage, managed futures), and 10 Trail Ridge Investment Advisors, LLC  private equity. The risk profiles of assets in the other category vary, but may be similar to or more volatile than equity. Your accounts are managed separately with your underlying investment strategies, restrictions, or investment limitations defined within the investment advisory agreement. Any restrictions, timing con- siderations, or special instructions that you impose may cause your account(s) to be traded later than the accounts of other TRIA clients until such restrictions, considerations, and/or instructions have been fulfilled or lifted. Model Allocations for Trailhead Financial Advisory Service™ – Each investment objective contains ranges for different asset classes. Target allocations can vary +/-5%. Portfolio rebalancing will be con- ducted periodically. 20/80 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily Fixed Income, and to a lesser extent, equity asset classes with a target allocation of 20% equities and 80% Fixed Income. 30/70 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily Fixed Income, and to a lesser extent, equity asset classes with a target allocation of 30% equities and 70% Fixed Income. 40/60 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily Fixed Income, and to a lesser extent, equity asset classes with a target allocation of 40% equities and 60% Fixed Income. 50/50 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily equity and fixed income asset classes with a target allocation of 50% equities and 50% fixed income. 60/40 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily equity, and to a lesser extent, fixed income asset classes with a target allocation of 60% equities and 40% fixed income. 70/30 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily equity, and to a lesser extent, fixed income asset classes with a target allocation of 70% equities and 30% Fixed Income. 80/20 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily equity, and to a lesser extent, fixed income asset classes with a target allocation of 80% equities and 20% fixed income. 90/10 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of primarily equity, and to a lesser extent, fixed income asset classes with a target allocation of 90% equities and 10% Fixed Income. 100/0 Target Allocation. This investment strategy seeks total return through exposure to a diversified portfolio of equity asset classes. Trail Ridge Investment Advisors, LLC 11  POTENTIAL RISKS Investing involves different levels of risk that can result in the loss of any profits and/or principal you have not realized. We manage your account in a manner consistent with your pre-determined risk tolerance and suitability profile. However, we cannot and do not guarantee that our efforts will be successful. Investing in securities involves the risk of loss, which you should be prepared to bear. Investing involves the assumption of risk, including: Company Risk: the risk when investing in stock positions. This is also commonly referred to as unsystematic risk and can be reduced through the appropriate diversification strategy. There is the risk that a company can perform poorly or that its value can be reduced on factors specific to its industry. Financial Risk: the risk that the investments we recommend to you perform poorly, which affect the price of your investments. Market Risk: the risk that the stock market will decline, decreasing the value of the securities we recommend to you along with it. Inflation Risk: the risk that the rate of price increases in the economy deteriorates the returns associated with securities. Political and Governmental Risk: the risk that the value of your investment may be affected by the introduction of new laws or regulations. Interest Rate Risk: the risk that the value of the investments we recommend to you will fall if interest rates rise. Call Risk: the risk that a security will be called away or purchased back from you when conditions are favorable to a bond issuer or option purchaser and unfavorable to you. Default Risk: the risk that a bond issuer is unable to pay the contractual interest or principal on a bond promptly or at all. Manager Risk: the risk that an investment adviser will fail to execute its stated investment strategy or outperform an applicable index. Industry Risk: the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of portfolios significantly invested in that industry. Alternative Investment Risk: Private placements, hedge funds, private equity, Real Estate Investment Trusts (REITs), Business Development Companies (BDCs), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative, and volatile, and an investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as to share price, valuation, and portfolio holdings. Complex tax structures often result in delayed tax reporting. Com- pared to mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher fees. Alternative investment managers typically exercise broad investment discretion and may apply similar strategies across multiple investment vehicles, resulting in less diversification. 12 Trail Ridge Investment Advisors, LLC  Cryptocurrency Risk: Cryptocurrency (notably, bitcoin), often referred to as virtual currency, digital currency, or digital assets, involves blockchain technology. Transacting on a blockchain depends in part specifically on the use of cryptographic keys that are required to access a user’s account (or ‘‘wallet’’). The theft, loss, or destruction of these keys impairs the value of ownership claims users have over the relevant assets being represented by the ledger. Cryptocurrency operates as a decentralized, peer-to-peer financial exchange and value storage that is used like money. Clients may be exposed to cryptocurren- cies other than bitcoin. Cryptocurrency operates without central authority or banks and is not backed by any government. Even indirectly, cryptocurrencies may experience very high volatility, and related investments may be affected by such volatility. Any investment in cryptocurrency will be made, if at all, through a mutual or exchange-traded fund; TRIA will not invest directly in any cryptocurrency. Cryptocurrency funds may trade at a significant premium to NAV. Cryptocurrency is also not legal tender. Federal, state, or foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. Because blockchain works by having every transaction build on every other transaction, participants can self-police any corruption, which can mitigate the need to depend on the current level of legal or government safeguards to monitor and control the flow of business transactions. As a result, companies engaged in such blockchain activities may be exposed to adverse regulatory action, fraudulent activity, or even failure. The SEC has issued a public report stating U.S. federal securities laws require treating some digital assets as securities. Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers, or malware. Cryptocurrency has a limited trading history, making it difficult for investors to evaluate investments in this cryptocurrency. Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including cryptocurrencies and their source code. Any threatened action that reduces confidence in a network’s long-term ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies. Cryptocurrency Tax Risk: Many significant aspects of the U.S. federal income tax treatment of in- vestments in cryptocurrency are uncertain, and such investments may produce income that is not treated as qualifying income for purposes of the income test applicable to regulated investment com- panies. The taxation will depend on a number of factors, including the nature of any investments made, the jurisdiction in which the income from such investments may be subject to tax, the jurisdiction in which the investor is subject to tax, and the applicable laws in any relevant jurisdiction. ITEM 9 Disciplinary Information As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events related to past or present investment clients. There have been no disciplinary, legal, or regulatory events related to us or any of our management persons. Trail Ridge Investment Advisors, LLC 13  ITEM 10 Other Financial Activities and Affiliations FINANCIAL INDUSTRY ACTIVITIES Neither TRIA nor its management persons are registered or have applications pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither TRIA nor its management persons are registered or have applications pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. Trail Ridge Trust Company, LLC (TRTC) is a wholly-owned subsidiary of TRIA’s parent company, Trail Ridge Wealth Management, Inc. TRTC operates under a trust company charter granted by the Wyoming Division of Banking and provides trust, estate, and other fiduciary services. TRIA may refer its clients to TRTC for various trust-related services. Furthermore, TRTC may act as a trustee for TRIA clients. This may create a conflict of interest; however, TRIA clients always have the right to use the service provider of their choice. SELECTION OF OTHER INVESTMENT ADVISERS We generally do not recommend or select third-party money managers (TPMMs) for our clients, but may do so for Trailhead clients. We may also do so if a client desires an investment strategy that we do not manage in-house. We will always act in the best interest of our clients when recommending or selecting TPMMs and receive no remuneration from any TPMM for doing so. If TRIA is billed di- rectly by a TPMM for its services, TRIA will pass that cost on to the applicable client account(s). The client always has the right to decide whether to act on our recommendations and whether to utilize the services of the recommended TPMM. The client always has the right to utilize the professional of his or her choice. All TPMMs will be properly registered as investment advisers in the proper jurisdictions. ITEM 11 Code of Ethics, Participation in Client Transactions, and Personal Trading CODE OF ETHICS TRIA has developed a Code of Ethics that applies to all of its supervised persons. TRIA and its investment adviser representatives (IARs) must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. TRIA has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle of our Code of Ethics, which also covers our insider trading and personal securities transactions policies and procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics. Our Code of Ethics is available to clients and prospective clients upon request. 14 Trail Ridge Investment Advisors, LLC  RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST TRIA may, from time to time, facilitate the purchase and/or sale of securities between its clients’ ac- counts. This is known as an agency cross transaction. TRIA will receive client consent prior to facili- tating such transactions, and clients will always have the right to revoke their consent to such transac- tions. Agency cross transactions present a potential conflict of interest in that TRIA may act as a broker for both parties to the transaction. To mitigate any possible conflicts of interest, TRIA will always seek the most favorable terms for its clients under the circumstances. TRIA receives no compensation from facilitating agency cross transactions. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There may be instances where an IAR will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which an IAR, its affiliates, or other clients may also have a position or interest. Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share exe- cution costs equally. Completed trade orders will be allocated according to the instructions from the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in the trade order. PERSONAL TRADING Employees are permitted to have personal securities accounts as long as personal investing practices are in line with fiduciary standards and regulatory requirements and do not conflict with their duty to TRIA and our clients. TRIA monitors and controls personal trading through pre-approval of all personal securities transactions or blackout periods imposed upon employees trading in the same secu- rities as TRIA. We forbid any officer or employee, either personally or on behalf of others, to trade on material, nonpublic information, or to communicate such information to others in violation of the law. ITEM 12 Brokerage Practices TRIA currently has custodial arrangements with National Financial Services LLC (NFS) and the Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab). NFS and Schwab are the unaffiliated, qualified custodians with which TRIA requires you to custody your accounts. If you are a Trailhead client, TRIA requires you to custody your accounts with NFS. NFS and Schwab are inde- pendent SEC-registered broker-dealers and members of FINRA and SIPC. NFS is an affiliate of Fi- delity Investments; Schwab is an affiliate of The Charles Schwab Corporation. TRIA uses a third-party platform to facilitate management of client assets in accounts held with custo- dians with which TRIA does not have a custodial arrangement (held away accounts). Held away ac- counts are typically defined contribution plan (e.g., 401(k), 403(b), etc.) participant accounts. The platform allows TRIA to avoid being deemed to have custody of client funds, because TRIA does not have direct access to client log-in credentials to effect trades. The client links his or her held away accounts to the platform via a secure website. Once the client’s held away accounts are linked to the platform, TRIA reviews their asset allocation and, if necessary, rebalances them using the investment options available. TRIA regularly reviews the investment options available to held away accounts, mon- itors them, and rebalances and implements TRIA’s strategies in the same manner as for non-held away accounts. TRIA is not affiliated with the third-party platform and receives no compensation for using it. Trail Ridge Investment Advisors, LLC 15  As a fiduciary, we are obligated to seek out the best execution of client transactions for the accounts that we manage. In general, the execution of securities transactions is at a total cost to process each transaction and is the most favorable under the circumstances. However, we do not limit the best execution to the lowest available price. Additional factors are taken into consideration when determin- ing the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review consists of reviewing the commission and fee structures of various broker-dealers, research platforms, and execution services. Accordingly, while we do consider competitive rates, we do not necessarily obtain the lowest possible commission rates for account transactions. Therefore, the overall services provided by unaffiliated broker-dealers and qualified custodians are evaluated to determine the best execution. You may pay trade execution charges and higher commissions through the trading platforms approved by us than through platforms that have not been approved by us. RESEARCH AND OTHER BENEFITS NFS and Schwab provide us and our clients with access to their institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to their retail cus- tomers. NFS and Schwab also make available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. These support services are generally available on an unsolicited basis, at no charge to advisors. Services that Benefit Our Clients. The institutional brokerage services of NFS and Schwab include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available include some to which we might not otherwise have access, or that would require a significantly higher minimum initial investment by our clients. The services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Our Clients. NFS and Schwab also make available to us other products and services that benefit us but may not directly benefit clients or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, potentially both that of NFS and Schwab and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at NFS or Schwab. In addition to investment research, NFS and Schwab also make availa- ble software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account state- ments); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • • provide pricing and other market data; • • facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. Services that Benefit Us. NFS and Schwab may also offer other services intended to help us manage and further develop our business enterprise. These services generally benefit only us and include: educational conferences and events technology, compliance, legal, marketing, and business consulting; • • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. 16 Trail Ridge Investment Advisors, LLC  Our Interest in These Services. The availability of these services from NFS and Schwab benefits us because we do not have to produce or purchase them. In addition, Schwab has agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our client's assets in accounts at Schwab reaches certain thresholds. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab provides an incentive for us to suggest or require the use of Schwab, rather than making such a decision based exclusively on the client’s interest in receiving the best value in custody services and the most favorable execution of transactions. This is a potential conflict of interest. We believe, however, that in the cases in which we may suggest or require the use of Schwab as custo- dian and broker, it is in the best interests of our clients because it is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit us. BROKERAGE-FOR-CLIENT REFERRALS We do not receive client referrals from broker-dealers. DIRECTED BROKERAGE We do not recommend, request, require, or permit clients to direct us to execute transactions through a specific broker-dealer other than those we recommend. TRADE AGGREGATION If we buy or sell the same securities on behalf of more than one client whose accounts are maintained with the same qualified custodian, then we may (but are under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, and/or more efficient execution. In such a case, we would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients, provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically dis- advantaged by this policy. SECURITIES LITIGATION – CLASS ACTION CLAIMS From time to time, class action lawsuits may be brought by shareholders against companies the securi- ties of which TRIA has purchased or maintained as investments for clients. TRIA retains the services of a third party (the provider) to prepare, file, accept, and process class action claims, settlement pay- ments resulting from the claims, government filings, and any required supporting documentation with claims administrators on behalf of TRIA’s clients. The provider may (a) request, gather, and/or copy all necessary documentation to file claim(s) on a client’s behalf; (b) forward to claims administrators any materials necessary to complete a client’s claim(s) in class action settlements; (c) accept, endorse, deposit, and otherwise deal with any check, instrument, or other payment from claims administrators; and (d) cause others to take these actions. TRIA will give to the provider the client trade data and/or supporting documentation necessary to perform the provider’s services. TRIA’s clients will be bound by the releases included in any settlement for which the provider obtains settlement payments on their behalf. The provider is compensated for its services by retaining a percentage of the settlement pay- ments resulting from class action claims. TRIA’s clients may opt out of this service in writing. Trail Ridge Investment Advisors, LLC 17  ITEM 13 Review of Accounts PERIODIC REVIEWS We review portfolio management accounts on an ongoing basis, but no less frequently than annually. These accounts will be reviewed by the client’s primary advisor, with spot checks performed by the Chief Compliance Officer. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash balance, and performance, as well as the general economic outlook and current invest- ment trends. REVIEW TRIGGERS We conduct periodic reviews to evaluate the current market, economic, and political events and how these may affect client accounts. Additional reviews may be triggered by these events or by events in a client’s financial or personal status. REGULAR REPORTS We do not provide regular written reports to portfolio management clients; however, these clients will receive account statements no less than quarterly. These statements show asset value by cash balances, security, unit cost, total cost, current per-share values, etc. Clients are urged to review the quarterly statements and notify us of any discrepancies. Clients are encouraged to phone or email us as often as they deem necessary to receive information regarding the investment tactics and strategies being fol- lowed. Generally, financial planning clients who pay financial planning fees on an hourly basis will receive a written financial plan upon completion and have the opportunity to discuss the plan with us. Our services will generally conclude upon delivery of the financial plan. ITEM 14 Client Referrals and Other Compensation TRIA does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to its clients. TRIA does not compensate third-party solicitors for client referrals. ITEM 15 Custody We are deemed to have custody of client funds and securities in the following circumstances: due to our ability to deduct management fees from clients’ accounts, when clients authorize us in a standing letter of authorization to disburse funds at our discretion to a third party, and where TRIA provides investment advisory services for trusts of which its affiliate, TRTC, serves as a trustee. We will not take physical custody of clients’ funds and will not assign or transfer trading authorization to another advi- sor. Clients will receive account statements from the qualified custodian(s) holding their funds and securities at least quarterly. The custodian’s account statements will indicate the amount of our man- agement fees deducted from the clients’ account(s) each billing period. These statements should be carefully reviewed by the client for accuracy. Item 5 – Fees and Compensation has additional infor- mation regarding our ability to deduct management fees from clients’ accounts. 18 Trail Ridge Investment Advisors, LLC  ITEM 16 Investment Discretion DISCRETIONARY AUTHORITY FOR TRADING If you are participating in our portfolio management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated account(s) and may also implement trades on a discretionary basis. We will have the limited authority to determine the type and number of securities that may be purchased, sold, or exchanged for your portfolio without obtaining your consent for each transaction. ITEM 17 Voting Client Securities TRIA acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated to it or for which it is deemed to have proxy voting authority. TRIA will vote proxies on behalf of a client solely in the best interest of that client and has established general guidelines for voting proxies. TRIA may also abstain from voting if, based on factors such as expense or difficulty of the exercise, it determines that a client’s interests are better served by abstaining. Further, because proxy proposals and individual company facts and circumstances may vary, TRIA may vote in a manner that is contrary to the general guidelines if it believes that doing so would be in a client’s best interest. If a proxy proposal presents a conflict of interest between TRIA and a client, then TRIA will disclose the conflict of interest to the client prior to the proxy vote and, if participating in the vote, will vote in accordance with the client's wishes. Clients may obtain a complete copy of the proxy voting policies and procedures by contacting TRIA in writing and requesting such information. Each client may also request, by contacting TRIA in writing, information concerning the manner in which proxy votes have been cast with respect to portfolio securities held by the client during the prior annual period. Notwithstanding the foregoing, if you are a Trailhead client, we do not have the authority to vote proxies regarding the securities held in your account. The responsibility for voting your securities increases our liability exposure and does not add enough value to the services we provide to you to justify the additional compliance and regulatory costs associated with voting your securities. Therefore, you are responsible for voting all proxies for securities held in your accounts. Typically, your qualified custodian will forward you your proxy information. Although we do not vote your proxies, you may contact us if you have questions about a particular proxy. ITEM 18 Financial Information TRIA is not required to include a balance sheet for its most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. TRIA is currently not and has not historically been in a financially precarious situation or the subject of a bankruptcy petition. Trail Ridge Investment Advisors, LLC 19